“Eco-friendly”, “climate-neutral”, a green leaf next to the company logo: wording like this appears on many websites of trades businesses, restaurants and service providers, often for years and without any intention to mislead. Since 27 September 2026, new rules apply in Germany (Federal Law Gazette 2026 I No. 43). The Third Act amending the Act against Unfair Competition (UWG) has added, among other things, four practices concerning environmental claims and sustainability labels to the list of commercial practices that are prohibited towards consumers in every case: generic environmental claims without recognised excellent environmental performance, claims about the whole that only concern a part, climate neutrality based on offsetting, and sustainability labels without a certification scheme. This article explains what each item of the annex requires, where its limits lie and how to replace affected sentences with concrete, provable statements. How a website itself can save energy is covered in the article on a website's CO2 footprint; this one is about what the site says about the business. It does not replace legal advice on an individual case.
What changed on 27 September
The act was published in the Federal Law Gazette issued on 19 February 2026 (Federal Law Gazette 2026 I No. 43).
Its Article 2 sets the date: subject to paragraph 2, the act enters into force on 27 September 2026. The exception in paragraph 2 concerns a provision that has nothing to do with environmental claims. The date is not a German special case: the act transposes Directive (EU) 2024/825, which requires all member states to apply the new rules from 27 September 2026 (Directive (EU) 2024/825, Article 4). The act contains no transitional rule for texts that were already online before. What counts is what is on the page today, not when it was written.
The new provisions sit in the annex to the UWG, often called the blacklist. Section 3(3) UWG attaches a strict consequence to it: the commercial practices listed in the annex are unlawful towards consumers in every case (UWG, Section 3(3)). Unlike general misleading practices, it does not matter whether the claim is likely to influence a purchasing decision in the individual case. Just as important for website copy is how broadly the law defines the term. Under Section 2(2) UWG, an environmental claim is any statement or representation not required by law, including representations through text, images, graphic elements or symbols such as labels, brand names, company names or product names, which states or implies that a product or trader has a positive or no impact on the environment or is less damaging to it than others (UWG, Section 2(2)). A green leaf symbol next to the name of a service can therefore fall under it just as much as a sentence in the body text.
- No. 2a: displaying a sustainability label that is neither based on a certification scheme nor established by public authorities.
- No. 4a: making a generic environmental claim for which the trader cannot demonstrate recognised excellent environmental performance.
- No. 4b: making an environmental claim about the entire product or the entire business when it only concerns one aspect or one activity.
- No. 4c: claiming, on the basis of offsetting greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment.
- No. 10a: presenting requirements that the law imposes on all products of a category as a distinctive feature of your own offer.
What the authorities found in green claims
The new bans have a history, and it plays out online.
In an EU-wide screening of websites, the European Commission and national consumer protection authorities examined 344 seemingly dubious environmental claims in detail (European Commission, 2020 sweep). In 37 percent of cases they found vague and general claims such as “conscious”, “eco-friendly” and “sustainable”; in 59 percent the companies had not provided easily accessible evidence for their claims (European Commission, 2020 sweep). In 42 percent of cases the authorities had reason to believe that the claims could be false or misleading (European Commission, 2020 sweep). A further figure concerns the scope of a claim. In its 2023 proposal for a directive, the Commission described the same sweep in more detail: in 36 percent of cases the authorities found it hard to tell whether a claim referred to the company or only to certain products (European Commission, 2023 proposal). The Commission's 2020 inventory had already rated 53.3 percent of the environmental claims examined as vague, misleading or unfounded, and 40 percent were unsubstantiated (European Commission, 2020 inventory). Labels look similar: of 232 active ecolabels assessed in the EU, almost half had weak verification or none at all (European Commission, 2023 proposal).
Case law was already strict before the amendment. In its judgment of 27 June 2024, the Federal Court of Justice held that an advertisement using an ambiguous environmental term such as “klimaneutral” (climate-neutral) must, as a rule, explain within the advertisement itself which specific meaning applies (Federal Court of Justice, I ZR 98/23). Explanatory notes outside the advertisement were not enough for the court. One of its reasons: reducing and offsetting CO2 emissions are not equivalent measures, and from a climate protection perspective reduction takes priority. The new annex items go further: they no longer just require an explanation, they ban certain claims outright.
No. 4a: generic environmental claims without proof
Item 4a prohibits making a generic environmental claim where the trader cannot demonstrate the recognised excellent environmental performance on which it is based (UWG, Annex no. 4a). The key word is generic.
Under the new definition, an environmental claim is only generic if it is not on a sustainability label and its specification is not given clearly and prominently on the same medium (UWG, Section 2(2)). The directive lists examples including “environmentally friendly”, “eco-friendly”, “green”, “nature's friend”, “ecological”, “climate friendly” and “carbon friendly” (Directive (EU) 2024/825, recital 9). Take care with “sustainable”, “conscious” and “responsible”. According to the directive, such claims should not even be based on recognised excellent environmental performance alone, because they also refer to social characteristics besides environmental ones (Directive (EU) 2024/825, recital 10). Anyone who writes “sustainable” should therefore all the more say what is meant: durable materials, repair before replacement, fair pay in the team or something else.
Two things follow from the definition. First, not every use of “eco-friendly” has been banned since September. If the page states right next to it, clearly visible and on the same page, what the environmental performance consists of, the claim is no longer generic under the definition. The directive illustrates the difference with an example: “climate friendly packaging” is a generic claim, whereas a statement that 100 percent of the energy used to produce this packaging comes from renewable sources is a specific one (Directive (EU) 2024/825, recital 9). The specific statement must then be true and provable, because the general ban on misleading practices still applies to it. Second, it is not only the wording that counts. According to the same recital, a statement combined with colours or images can also amount to a generic environmental claim. A homepage in shades of green with a leaf motif and the sentence “We think about tomorrow” is therefore worth a second look.
The exception that item 4a itself provides does not help most businesses. Recognised excellent environmental performance only means performance in line with Regulation (EC) No 66/2010 on the EU Ecolabel, with officially recognised ecolabels under DIN EN ISO 14024 type I, or with top environmental performance under other Union law (UWG, Section 2(2)). In Germany, the Blue Angel is such a type I ecolabel; more than 70,000 products and services from over 1,800 companies carry it (Blue Angel). Labels like this are awarded to specific products and services under fixed criteria, not to a business as a whole. A painter who uses wall paint with the Blue Angel can say exactly that; it does not make the whole painting business “eco-friendly”.
Scroll table sideways
| Generic wording | Specific and checkable | What you keep on file |
|---|---|---|
| Eco-friendly painting | On request we paint interior walls with paints that carry the Blue Angel | Product name, data sheet, validity of the label |
| Green energy in our business | The roof of our workshop carries a solar installation that covers part of our electricity needs | System data, annual yield, consumption |
| Climate-neutral call-outs | Within the city we drive to jobs in an electric van, outside it with diesel | Vehicle list, service area |
| Sustainable renovation | We repair windows and doors before we offer a replacement | Process in the quote, examples from practice |
| Ecological cleaning | For routine cleaning we use products with the EU Ecolabel and dose them as the manufacturer specifies | Product list with label and licence number |
| Regional and eco-conscious | We buy vegetables from farms in the area; their origin is shown on the menu | Supplier list |
The explanation belongs next to the claim
No. 4c: “climate-neutral” through offsetting
Item 4c is the most clearly worded. It prohibits making a claim, based on the offsetting of greenhouse gas emissions, that a product has a neutral, reduced or positive impact on the environment in terms of greenhouse gas emissions (UWG, Annex no. 4c). The directive states expressly that product means goods and services alike. As examples it names “climate neutral”, “CO2 neutral certified”, “carbon positive”, “climate net zero”, “climate compensated”, “reduced climate impact” and “limited CO2 footprint” (Directive (EU) 2024/825, recital 12). A “climate-neutral bathroom renovation” based on purchased certificates therefore falls squarely under the ban.
According to the directive, such claims remain permissible only if they are based on the actual impact over the life cycle of the product and not on offsetting outside its value chain. At the same time, the directive makes clear that the ban should not prevent companies from advertising their investments in environmental initiatives, including carbon credit projects, as long as this is done in a way that is not misleading (Directive (EU) 2024/825, recital 12). For your website this means: a sentence such as “We support a peatland conservation project in our region” describes what you do. A sentence such as “This makes our work climate-neutral” claims an effect on your service that the law no longer allows where offsetting is involved.
The whole business: no. 4b and targets for tomorrow
Item 4c speaks of the product. Whether it also covers a claim about the business as a whole is left open by the wording; in any case, other rules apply to a “climate-neutral business” or a “sustainable company”.
Without a clearly highlighted specification, such a claim is a generic environmental claim under item 4a, and proof of recognised excellent environmental performance is unlikely to succeed for a business as a whole. Item 4b additionally prohibits environmental claims about the entire business when they only concern a particular activity (UWG, Annex no. 4b). As an example, the directive mentions a trader who creates the impression of using only energy from renewable sources although several of its facilities still run on fossil fuels (Directive (EU) 2024/825, recital 11). Applied to a trades business: the solar installation on the workshop does not make the drives to the building site emission-free.
Targets for the future have their own rule. Anyone who advertises a future environmental performance to consumers, such as “climate-neutral by 2030”, acts misleadingly under the new item 4 of Section 5(3) UWG if this is done without clear, objective, publicly available and verifiable commitments set out in a detailed and realistic implementation plan (UWG, Section 5(3) no. 4). The plan must include measurable and time-bound targets, name the allocation of resources and be reviewed regularly by an independent external expert whose findings are made available to consumers. For many small businesses this effort is too great. The better route is then not to write about the future but about what has already been done: the cargo bike for short trips, the heat pump in the workshop, the repair that saves a replacement. Statements like these can be backed up and need no external reviewer.
No. 2a: home-made seals and badges
Under Section 2(2) UWG, a sustainability label is a voluntary public or private trust mark, quality mark or equivalent intended to highlight or promote a product, a process or a business with regard to its environmental or social characteristics (UWG, Section 2(2)). Under item 2a, displaying such a label is prohibited if it is neither based on a certification scheme nor established by public authorities (UWG, Annex no. 2a). A certification scheme requires, among other things, that it is open to all traders on transparent terms and that an independent third party monitors compliance (UWG, Section 2(2)). A self-designed badge such as “Eco business” or “Green trades” in the header of the website is likely to fall under the definition and meets none of these conditions. It should come off the page or be replaced by a list of concrete measures.
Genuine labels can stay if they are shown next to what they were awarded for. The Blue Angel is a type I ecolabel under DIN EN ISO 14024 (Blue Angel); if you use products with this label, you can state that for the product in question. Which labels involve which checks is shown on the Siegelklarheit portal, which is funded by the German Federal Ministry for Economic Cooperation and Development. How to show a master craftsman certificate, guild membership and verified certificates credibly is described in the article on trust signals such as seals and the master craftsman certificate.
Another new item concerns matters of course. Under item 10a, it is prohibited to present requirements that apply by law to all products of the category in question on the Union market as a distinctive feature of your own offer (UWG, Annex no. 10a). If you highlight a property that the law requires of all products of this kind anyway as an advantage over other businesses, name it plainly as an obligation or leave it out. How to present prices and other advertising claims properly is explained in the article on pricing and advertising claims.
How to check your website copy
The review can be done in one pass if you work systematically. The order is the same as when decluttering outdated statements: collect first, then classify, then replace.
It is important not to look at the body text only. Environmental claims like to hide in image captions, alt texts, meta descriptions and graphics.
- Collect every place. Homepage, about page, service pages, footer, image captions, alt texts, page titles and meta descriptions. Graphics with embedded text belong on the list too.
- Search for signal words. The search list below covers the most common terms; add words from your own trade.
- Classify every finding. Seal without certification (2a), generic claim (4a), whole instead of part (4b), offsetting (4c), future target (Section 5(3)), legal obligation as an advantage (10a).
- Replace or delete. Whatever can be stated specifically and with proof becomes specific. Whatever cannot be proven goes.
- File the evidence. Every remaining environmental claim needs proof: data sheet, contract, invoice or certificate with its validity.
- Check images and colours. Leaves, globes and green ticks next to a vague claim reinforce it.
- Set a reminder. Certificates expire, vehicles get replaced. A date in the calendar for the next review keeps the statements up to date.
Generic terms (no. 4a, 4b):
eco-friendly environmentally friendly green eco ecological
nature-friendly climate-friendly sustainable conscious
responsible carbon-friendly resource-saving
Offsetting (no. 4c):
climate-neutral CO2-neutral carbon positive climate positive
climate compensated net zero reduced CO2 footprint
Future targets (Section 5(3) UWG):
by 20.. on the way to net zero by we will be climate-neutral
Seals and symbols (no. 2a):
own badges, leaf and globe icons, “certified” without a certifier
Replacement pattern:
What we do + to what extent + since when + which proofPainting business
Before: “We paint eco-friendly.” After: “For interiors we use wall paints with the Blue Angel; the quote names the paint we will use.”
Plumbing and heating
Before: “Climate-neutral bathroom renovation.” After: “We support a peatland conservation project in the region. It does not reduce the emissions of our work; for that, we use an electric van within the city.”
Café and restaurant
Before: a self-designed seal “Green café”. After: “We buy milk and eggs from farms in the area; the names of the farms are on the menu.”
In the XICflow editor: replace with confirmation
If you run your website with XICflow, you put the replacement wording straight into the editor.
A double click on a text in the preview makes it editable; this is how you change headings, paragraphs and lists in the layout without going through a form. For searching across many pages, the AI assistant in the editor helps: it can find blocks by their content and asks when there are several matches instead of guessing. It places changes to blocks as a card in the chat history; they only take effect once you choose “Apply”. Before every change the assistant carries out itself, a restore point is saved. The features are shown on the services page, the chat details in the chapter Working with the AI.
The AI does not know your evidence
The homepage deserves particular attention in the review, because it carries the statements every visitor reads first; what belongs on the first screen is described in the article on the homepage's first screen. If you offer repairs, you can describe the repair itself instead of writing “sustainable”; how a repair page is set up is shown in the article on the repair page and the European form. How a description of your business becomes a website that you then edit yourself is shown in How XICflow works.
The rule of thumb